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Privacy Policy 

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Last updated: 8 July 2026

 

Introduction

 

I am Kristina Smith, the Data Controller responsible for the personal information collected and processed through this website and my private counselling practice.

 

I collect and process personal information only where it is necessary to provide safe, ethical and professional counselling services, comply with my legal and professional obligations, and operate my practice.

 

This Privacy Policy explains how I collect, use, store and protect your personal information when you:

 

  • Visit my website;

  • Contact me by email or telephone;

  • Enquire about counselling services;

  • Attend counselling sessions or receive counselling services from me.

 

I process personal information in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

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Contact Details

 

Name: Kristina Smith

 

Email: bloomspacecounselling@gmail.com

 

ICO Registration Number: [Insert ICO registration number or “Application pending”]

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Professional Membership

 

I am a registered member of the British Association for Counselling and Psychotherapy (BACP) and work in accordance with the BACP Ethical Framework for the Counselling Professions.

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Information I Collect

 

Website Visitors

 

When you visit my website, certain technical information may be collected automatically, including:

 

  • IP address;

  • Browser type and version;

  • Device information;

  • Website usage information;

  • Security and diagnostic information.

 

Enquiries

 

If you contact me by email or telephone, I may collect:

 

  • Your name;

  • Email address;

  • Telephone number;

  • Information you choose to share about your circumstances or reasons for seeking counselling.

 

Clients

 

If you become a client, I may collect:

 

  • Contact details;

  • Date of birth;

  • Emergency contact information;

  • GP details (where appropriate);

  • Appointment information;

  • Session notes;

  • Information relating to your health, wellbeing, personal circumstances and counselling needs.

 

This may include special category data, including information relating to your physical or mental health and other sensitive personal information you choose to share during counselling.

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Why I Collect Information

 

I use your personal information to:

 

  • Respond to enquiries;

  • Arrange and manage appointments;

  • Provide counselling services;

  • Maintain appropriate professional records;

  • Communicate with you;

  • Undertake professional clinical supervision;

  • Fulfil safeguarding responsibilities;

  • Process payments and maintain financial records;

  • Comply with legal, regulatory, insurance and professional obligations;

  • Protect the security and operation of my practice and website.

 

Lawful Basis for Processing

 

Under UK data protection law, I rely on one or more of the following lawful bases:

 

Contract

 

Where processing is necessary to take steps at your request before entering into a counselling agreement, and to provide counselling services.

 

Legal Obligation

 

Where processing is necessary to comply with legal, regulatory or professional obligations, including safeguarding responsibilities, tax and accounting requirements, responding to lawful requests from authorities, and maintaining appropriate records.

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Legitimate Interests

 

Where processing is necessary for the legitimate interests of operating and administering my private counselling practice, including practice management, website security, service improvement and maintaining appropriate business records.

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Special Category Data

 

As a counsellor, I process special category personal data, including information about your physical or mental health and other sensitive information you choose to share.

 

Where applicable, this information is processed in accordance with Article 9 UK GDPR and Schedule 1 of the Data Protection Act 2018 because it is necessary for the provision and management of counselling services. In limited circumstances, I may also rely on your explicit consent where this is the appropriate lawful basis.

 

Providing Your Information

 

Some personal information is necessary before counselling can begin, including your contact details, emergency contact information and relevant health information where appropriate.

 

If you choose not to provide information that is necessary for me to provide safe and ethical counselling, I may be unable to offer or continue counselling services.

 

Confidentiality

 

Counselling sessions are confidential. However, confidentiality may be limited where:

 

  • There is a serious risk of harm to you or another person;

  • Safeguarding concerns arise involving a child or vulnerable adult;

  • Disclosure is required by law;

  • A court orders disclosure;

  • Professional or ethical obligations require action.

 

Where appropriate and safe to do so, I will aim to discuss any necessary disclosure with you before information is shared.

 

Sharing Information

 

Your information will only be shared where necessary and appropriate.

 

This may include:

 

  • My clinical supervisor;

  • Regulatory or professional bodies where required;

  • Safeguarding agencies;

  • Law enforcement agencies or the courts where legally required;

  • Trusted service providers who support the operation of my practice, such as secure email providers, website hosting providers, cloud storage providers or online video consultation services. These organisations only process personal information where appropriate safeguards are in place.

 

Where disclosure of client records is requested by a court, the police, a solicitor or another authorised organisation, I will only disclose information where I am legally required or authorised to do so.

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Clinical Supervision

 

As required by the BACP Ethical Framework, I regularly discuss my counselling work with a qualified clinical supervisor to ensure that I am working safely, ethically and in my clients’ best interests.

 

Where possible, I use a code or pseudonym so that clients cannot be readily identified. My supervisor is also bound by professional and ethical duties of confidentiality.

 

Online Counselling

 

Online counselling sessions are conducted using Google Meet.

 

Google processes certain technical information to provide this service and may process data outside the United Kingdom using recognised safeguards in accordance with applicable data protection law.

 

Although reasonable measures are taken to maintain confidentiality and security, no internet-based communication can ever be guaranteed to be completely secure. Clients are encouraged to use a private location, secure internet connection and password-protected, up-to-date devices.

 

Electronic Records and Security

 

Client assessments and session notes are stored electronically in separate secure locations to help protect confidentiality.

 

Appropriate technical and organisational security measures include:

 

  • Password-protected devices and accounts;

  • Secure storage systems;

  • Access controls;

  • Security software and regular updates;

  • Encryption where available;

  • Access to client records restricted solely to me.

 

Session notes are brief professional records maintained in accordance with ethical and legal requirements.

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Payments

 

Where payments are made by bank transfer, payment information is processed by my bank for the purposes of completing the transaction and maintaining financial records.

 

I do not store debit or credit card details.

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Retention of Records

 

Client records will normally be retained for seven years after the counselling relationship ends unless there is a legal, professional, safeguarding, insurance or regulatory reason to retain them for longer.

 

After the applicable retention period, records will be securely deleted or destroyed.

 

Your Rights

 

Under UK GDPR and the Data Protection Act 2018 you have the right to:

 

  • Access your personal information;

  • Request correction of inaccurate information;

  • Request deletion of your information in certain circumstances;

  • Request restriction of processing;

  • Object to processing where applicable;

  • Request data portability where applicable;

  • Withdraw consent where consent is the lawful basis for processing.

 

These rights are not absolute. In some circumstances, legal exemptions may apply to counselling records, particularly where disclosure could seriously affect the physical or mental health of any individual or reveal information about another person.

 

If you wish to exercise any of these rights, please contact me using the details provided above.

 

Complaints

 

If you have any concerns about how I use your personal information, I encourage you to contact me in the first instance so that I can try to resolve your concerns.

 

If you make a Subject Access Request, I will normally respond within one month, unless the request is particularly complex, in which case I will inform you if additional time is required in accordance with UK GDPR.

 

Where required by law, I will notify the Information Commissioner’s Office (ICO) and affected individuals of any personal data breach within the applicable legal timescales.

 

You also have the right to complain directly to the Information Commissioner’s Office (ICO):

 

Website: https://ico.org.uk/make-a-complaint

 

Telephone: 0303 123 1113

 

Cookies

 

This website may use cookies to ensure it functions correctly.

 

Where non-essential cookies (such as analytics or marketing cookies) are used, you will be provided with information about these cookies and given the opportunity to accept or manage your preferences.

 

You can also manage cookies through your browser settings.

 

Changes to this Privacy Policy

 

I may update this Privacy Policy from time to time to reflect changes in legislation, professional guidance or the operation of my practice.

 

The most recent version will always be available on my website.

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